Producer responsibility organizations must now report detailed cost and pricing data for hazardous and special products programs

Plain-language summary · AI-assisted · not legal advice

Producer responsibility organizations (PROs) that manage hazardous and special products (HSP) programs on behalf of producers must now include detailed financial information in their annual reports. Required new disclosures include total program costs, cost-per-tonne figures for collection and management activities (calculated using specified formulas), and a full breakdown of the methodology used to set fees charged to producer clients — including any fee schedules, groupings, and per-unit cost figures. PROs must also file a one-time backdated report covering 2023, 2024, and 2025, submitted no later than December 31, 2026. Importantly, the new cost and pricing data reported under these provisions is explicitly shielded from public posting on the Registry, keeping it confidential. PROs should review their cost-tracking and fee-documentation practices to ensure they can produce the required information for each type of HSP they handle.

Who this affects: producer responsibility organizations · HSP producers retaining PROs · HSP haulers · HSP processors and disposal facilities